The definitions of face covering and surgical mask in the proposed standard apparently aim to categorically disqualify, for reason unclear, use of surgical masks as face coverings.  As an unintended result, the terminology has potential to increase employee risk, eliminate highly effective face covering options and thereby trigger a rush to buy compliant face coverings which may result in inadequate availability.  

Consider the following.

Face coverings are readily available which are made of ultra-thin, two ply fabric.   These products are targeted at the consumer who values comfort over all else. 

Surgical masks are readily available which are made of 3 LAYERS of meltblown polypropylene FABRIC.  This material is in fact WASHABLE and BREATHABLE.  When properly fitted, such masks provide SNUG FIT WITHOUT GAPS.  By these metrics, such surgical masks satisfy the face covering definition in the standard. if not for their dispenser box bearing the label "surgical mask". 

Comparing the efficacy of the two types of product described above would likely find the "face covering" desperately inferior to the "surgical mask".   

If DOLI is interested in requiring face coverings to have specified characteristics, then those specifications should be clear, unambiguous and without subjectivity.  As the language stands now, although well intended, it risks forcing employers to abandon effective masks for less effective face coverings.  That's not sensible.